Nestor v. Comm'r
United States Tax Court
This opinion addresses petitioner's (P) 1992 through 1997 (1992-97) tax years. Respondent (R) issued notices of deficiency to petitioner (P) for tax years 1990 through 1997 (1990-97). P received the notices of deficiency for tax years 1992-97 but did not file a petition for redetermination with the Court.
Read the full summary
This opinion addresses petitioner's (P) 1992 through 1997 (1992-97) tax years. Respondent (R) issued notices of deficiency to petitioner (P) for tax years 1990 through 1997 (1990-97). P received the notices of deficiency for tax years 1992-97 but did not file a petition for redetermination with the Court. R issued to P a notice of intent to levy with respect to P's taxes due for tax years 1990-97. P requested and R held a hearing pursuant to sec. 6330(b), I.R.C., relating to P's tax years 1990-97. In his request for a hearing, P requested that R provide him copies of the assessment records.…
1Opinion of the Court
Colvin, Judge:
On April 7, 2000, respondent sent petitioner a Notice of Determination Concerning Collection Action(s) Under Sections 6320 and/or 6330 (the lien or levy determination), in which respondent determined to proceed with collection of deficiencies in petitioner’s income tax, additions to tax, interest, and the frivolous return penalty1 for 1990 through 1997 (1990-97).
In this opinion, we decide:(1) Whether petitioner may contest his underlying tax liability for tax years 1992-97. We hold that he may not.(2) Whether respondent’s determination to proceed with collection with respect to…
2Cases cited7 opinions
- Davis v. CommissionerUnited States Tax Court · 2000
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Van Es v. CommissionerUnited States Tax Court · 2000
- Stamos v. CommissionerUnited States Tax Court · 1990
2 more not listed; retrieve them via the Exa API.
3Cited by132 opinions
- Craig v. Comm'rUnited States Tax Court · 2002
- Thomas W. Roberts v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2003
- Roberts v. Comm'rUnited States Tax Court · 2002
- Robinette v. Comm'rUnited States Tax Court · 2004
- Cox v. Comm'rUnited States Tax Court · 2006
127 more not listed; retrieve them via the Exa API.